Pete Miller examines the effect the Bamberg case will have on transactions in securities
The case of Marcus Bamberg v HMRC (TC00618) considers the application of Circumstance D of the transactions insecurities legislation. The legislation that applied to Mr Bamberg was the old legislation at ICTA 1988 ss 703–709 rewritten to ITA 2007 Pt 13 Ch 1 as the transactions occurred between 2000 and 2004.
Transactions
Mr Bamberg owned a company called The Trade Exchange Limited (TTEL) a profitable company with distributable reserves of around £2 million. White Clover Limited (WCL) was an independent company with £15 million negative distributable reserves a liability to repay loan stock of £15 million and no other assets. Mr Bamberg acquired the loan stock for £237 000 and the shares for a nominal sum. The shares were then sold to TTEL so that WCL became a wholly owned subsidiary.
TTEL...
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Pete Miller examines the effect the Bamberg case will have on transactions in securities
The case of Marcus Bamberg v HMRC (TC00618) considers the application of Circumstance D of the transactions insecurities legislation. The legislation that applied to Mr Bamberg was the old legislation at ICTA 1988 ss 703–709 rewritten to ITA 2007 Pt 13 Ch 1 as the transactions occurred between 2000 and 2004.
Transactions
Mr Bamberg owned a company called The Trade Exchange Limited (TTEL) a profitable company with distributable reserves of around £2 million. White Clover Limited (WCL) was an independent company with £15 million negative distributable reserves a liability to repay loan stock of £15 million and no other assets. Mr Bamberg acquired the loan stock for £237 000 and the shares for a nominal sum. The shares were then sold to TTEL so that WCL became a wholly owned subsidiary.
TTEL...
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